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Append-only logs replicated to multiple places is probably illegal under the GDPR. People have the right to demand all data about them is deleted, e.g. once the

Append-only logs replicated to multiple places is probably illegal under the GDPR. People have the right to demand all data about them is deleted, e.g. once they are no longer Travelex customers. An interesting question is would you rather your bank leaked some personal information about you, or would you rather they lost all your information, and therefore all of your money?

Kalium 7y ago
Travelex, as a financial services company, is probably obligated to retain records. GDPR defers to these obligations. A company outside finance might definitely have these problems!
- Jimw338 7y ago
  > financial services company, is probably obligated to retain records. GDPR defers to these obligations. Gee - how long until the GDPR-o-crats demand a fine from a company (possibly the "right to be forgotten" thing), and the company then uses the defense that "we would have destroyed the information, except for some other EU regulation.. You figure your own way out of that logical puzzle!"
  - Kalium 7y ago
    Fortunately, GDPR explicitly spells out that it defers to other legal retention obligations.
- TheCoelacanth 7y ago
  They're obligated to retain some information for a certain period of time, but certainly not all information that they have and not forever.
  - Kalium 7y ago
    You're absolutely right. In this case, it means that an append-only data store with a fixed retention time might be a perfectly reasonable way to store certain kinds of records. This means that an append-only data store is not guaranteed to run up against deletion requirements in all cases. In my opinion, this is particularly salient and worth being aware of when the conversation centers around a financial company, data storage, GDPR, and deletion requirements. It is possibly not always likely to be as simple as "use append-only" or "append-only likely to be illegal".
GhettoMaestro 7y ago
You could conceptually only allow the app (service accounts) to write, but have admin (maintenance accounts) that can also perform delete operations. Although I'd like to have a totally immutable record of deletions, given that it doesn't violate GPDR.
thu2111 7y ago
Obviously everyone would much prefer the former. GDPR is a very bad law for many reasons, but rendering many basic IT strategies for robustness "illegal" (maybe) is one of them. Of course GDPR defenders tend to take a stance of, anything reasonable is actually not illegal under GDPR even if it might appear to be so at first. It really is a horribly vague and useless piece of law making. I really hope the UK scraps it after Brexit, though I don't hold out much hope.

Kalium 7y ago

Travelex, as a financial services company, is probably obligated to retain records. GDPR defers to these obligations. A company outside finance might definitely have these problems!

Jimw338 7y ago
> financial services company, is probably obligated to retain records. GDPR defers to these obligations. Gee - how long until the GDPR-o-crats demand a fine from a company (possibly the "right to be forgotten" thing), and the company then uses the defense that "we would have destroyed the information, except for some other EU regulation.. You figure your own way out of that logical puzzle!"
- Kalium 7y ago
  Fortunately, GDPR explicitly spells out that it defers to other legal retention obligations.
TheCoelacanth 7y ago
They're obligated to retain some information for a certain period of time, but certainly not all information that they have and not forever.
- Kalium 7y ago
  You're absolutely right. In this case, it means that an append-only data store with a fixed retention time might be a perfectly reasonable way to store certain kinds of records. This means that an append-only data store is not guaranteed to run up against deletion requirements in all cases. In my opinion, this is particularly salient and worth being aware of when the conversation centers around a financial company, data storage, GDPR, and deletion requirements. It is possibly not always likely to be as simple as "use append-only" or "append-only likely to be illegal".

GhettoMaestro 7y ago

You could conceptually only allow the app (service accounts) to write, but have admin (maintenance accounts) that can also perform delete operations. Although I'd like to have a totally immutable record of deletions, given that it doesn't violate GPDR.

thu2111 7y ago

Obviously everyone would much prefer the former. GDPR is a very bad law for many reasons, but rendering many basic IT strategies for robustness "illegal" (maybe) is one of them. Of course GDPR defenders tend to take a stance of, anything reasonable is actually not illegal under GDPR even if it might appear to be so at first. It really is a horribly vague and useless piece of law making. I really hope the UK scraps it after Brexit, though I don't hold out much hope.